Privacy Policy

Last updated: February 06, 2026
This Privacy Policy describes Our policies and procedures on the collection, use and
disclosure of Your information when You use the Service and tells You about Your privacy
rights and how the law protects You.
We use Your Personal Data to provide and improve the Service. By using the Service, You
agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words whose initial letters are capitalized have meanings defined under the following
conditions. The following definitions shall have the same meaning regardless of whether
they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:
Account means a unique account created for You to access our Service or parts of
our Service.
Affiliate means an entity that controls, is controlled by, or is under common control
with a party, where “control” means ownership of 50% or more of the shares, equity
interest or other securities entitled to vote for election of directors or other
managing authority.
Business, for the purpose of CCPA/CPRA, refers to the Company as the legal entity
that collects Consumers’ personal information and determines the purposes and
means of the processing of Consumers’ personal information, or on behalf of which
such information is collected and that alone, or jointly with others, determines the
purposes and means of the processing of consumers’ personal information, that
does business in the State of California.
CCPA and/or CPRA refers to the California Consumer Privacy Act (the “CCPA”) as
amended by the California Privacy Rights Act of 2020 (the “CPRA”).
Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Privacy
Policy) refers to Fig Tree Homes LLC, 1660 W Chapman Dr Sanger, TX 76266.
Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a
California resident. A resident, as defined in the law, includes (1) every individual
who is in the USA for other than a temporary or transitory purpose, and (2) every
individual who is domiciled in the USA who is outside the USA for a temporary or
transitory purpose.
Cookies are small files that are placed on Your computer, mobile device or any
other device by a website, containing the details of Your browsing history on that
website among its many uses.
Country refers to: Texas, United States
Device means any device that can access the Service such as a computer, a cell
phone or a digital tablet.
Do Not Track (DNT) is a concept that has been promoted by US regulatory
authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet
industry to develop and implement a mechanism for allowing internet users to
control the tracking of their online activities across websites.
Personal Data (or “Personal Information”) is any information that relates to an
identified or identifiable individual.
For the purposes of the CCPA/CPRA, Personal Data means any information that
identifies, relates to, describes or is capable of being associated with, or could
reasonably be linked, directly or indirectly, with You.
We use “Personal Data” and “Personal Information” interchangeably unless a law
uses a specific term.
Service refers to the Website.
Service Provider means any natural or legal person who processes the data on
behalf of the Company. It refers to third-party companies or individuals employed
by the Company to facilitate the Service, to provide the Service on behalf of the
Company, to perform services related to the Service or to assist the Company in
analyzing how the Service is used.
Third-Party Social Media Service refers to any website or any social network
website through which a User can log in or create an account to use the Service.
Usage Data refers to data collected automatically, either generated by the use of the
Service or from the Service infrastructure itself (for example, the duration of a page
visit).
Website refers to Fig Tree Homes, accessible from www.figtreehomes.com.
You means the individual accessing or using the Service, or the company, or other
legal entity on behalf of which such individual is accessing or using the Service, as
applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable
information that can be used to contact or identify You. Personally identifiable information
may include, but is not limited to:

• Email address
• First name and last name
• Phone number

Usage Data

Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP
address), browser type, browser version, the pages of our Service that You visit, the time
and date of Your visit, the time spent on those pages, unique device identifiers and other
diagnostic data.
When You access the Service by or through a mobile device, We may collect certain
information automatically, including, but not limited to, the type of mobile device You use,
Your mobile device’s unique ID, the IP address of Your mobile device, Your mobile
operating system, the type of mobile Internet browser You use, unique device identifiers
and other diagnostic data.
We may also collect information that Your browser sends whenever You visit Our Service or
when You access the Service by or through a mobile device.

Information from Third-Party Social Media Services

The Company allows You to create an account and log in to use the Service through the
following Third-Party Social Media Services:

• Google
• Facebook
• Instagram
• X (Twitter)
• LinkedIn

If You decide to register through or otherwise grant Us access to a Third-Party Social Media
Service, We may collect Personal Data that is already associated with Your Third-Party
Social Media Service’s account, such as Your name, Your email address, Your activities or
Your contact list associated with that account.
You may also have the option of sharing additional information with the Company through
Your Third-Party Social Media Service’s account. If You choose to provide such information
and Personal Data, during registration or otherwise, You are giving the Company
permission to use, share, and store it in a manner consistent with this Privacy Policy.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and
store certain information. Tracking technologies We use include beacons, tags, and scripts
to collect and track information and to improve and analyze Our Service. The technologies
We use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can
instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent.
However, if You do not accept Cookies, You may not be able to use some parts of our
Service.

• Web Beacons. Certain sections of our Service and our emails may contain small
electronic files known as web beacons (also referred to as clear gifs, pixel tags, and
single-pixel gifs) that permit the Company, for example, to count users who have visited
those pages or opened an email and for other related website statistics (for example,
recording the popularity of a certain section and verifying system and server integrity).
Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your
personal computer or mobile device when You go offline, while Session Cookies are deleted
as soon as You close Your web browser.
Where required by law, we use non-essential cookies (such as analytics, advertising, and
remarketing cookies) only with Your consent. You can withdraw or change Your consent at
any time using Our cookie preferences tool (if available) or through Your browser/device
settings. Withdrawing consent does not affect the lawfulness of processing based on
consent before its withdrawal.
We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through
the Website and to enable You to use some of its features. They help to authenticate
users and prevent fraudulent use of user accounts. Without these Cookies, the
services that You have asked for cannot be provided, and We only use these Cookies
to provide You with those services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the
Website.

Functionality Cookies

Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow Us to remember choices You make when You use the
Website, such as remembering your login details or language preference. The
purpose of these Cookies is to provide You with a more personal experience and to
avoid You having to re-enter your preferences every time You use the Website.

Tracking and Performance Cookies

Type: Persistent Cookies
Administered by: Third Parties
Purpose: These Cookies are used to track information about traffic to the Website
and how users use the Website. The information gathered via these Cookies may
directly or indirectly identify you as an individual visitor. This is because the
information collected is typically linked to a pseudonymous identifier associated
with the device you use to access the Website. We may also use these Cookies to test
new pages, features or functionality of the Website to see how our users react to
them.
For more information about the cookies we use and your choices regarding cookies, please
visit our Cookies Policy or the Cookies section of Our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage Your Account: to manage Your registration as a user of the Service. The
Personal Data You provide can give You access to different functionalities of the Service
that are available to You as a registered user.

• For the performance of a contract: the development, compliance and undertaking of
the purchase contract for the products, items or services You have purchased or of any
other contract with Us through the Service.

• To contact You: To contact You by email, telephone calls, SMS, or other equivalent
forms of electronic communication, such as a mobile application’s push notifications
regarding updates or informative communications related to the functionalities,
products or contracted services, including the security updates, when necessary or
reasonable for their implementation.

• To provide You with news, special offers, and general information about other goods,
services and events which We offer that are similar to those that you have already
purchased or inquired about unless You have opted not to receive such information.

• To manage Your requests: To attend and manage Your requests to Us.
• To deliver targeted advertising to You: We may use Your information to develop and
display content and advertising (and work with third-party vendors who do so) tailored
to Your interests and/or location and to measure its effectiveness.

• For business transfers: We may use Your Personal Data to evaluate or conduct a
merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer
of some or all of Our assets, whether as a going concern or as part of bankruptcy,
liquidation, or similar proceeding, in which Personal Data held by Us about our Service
users is among the assets transferred.

• For other purposes: We may use Your information for other purposes, such as data
analysis, identifying usage trends, determining the effectiveness of our promotional
campaigns and to evaluate and improve our Service, products, services, marketing and
your experience.
We may share Your Personal Data in the following situations:

• With Service Providers: We may share Your Personal Data with Service Providers to
monitor and analyze the use of our Service, to advertise on third party websites to You
after You visited our Service, to contact You.

• For business transfers: We may share or transfer Your Personal Data in connection
with, or during negotiations of, any merger, sale of Company assets, financing, or
acquisition of all or a portion of Our business to another company.

• With Affiliates: We may share Your Personal Data with Our affiliates, in which case we
will require those affiliates to honor this Privacy Policy. Affiliates include Our parent
company and any other subsidiaries, joint venture partners or other companies that We
control or that are under common control with Us.

• With business partners: We may share Your Personal Data with Our business partners
to offer You certain products, services or promotions.

• With other users: If Our Service offers public areas, when You share Personal Data or
otherwise interact in the public areas with other users, such information may be viewed
by all users and may be publicly distributed outside. If You interact with other users or
register through a Third-Party Social Media Service, Your contacts on the Third-Party
Social Media Service may see Your name, profile, pictures, and description of Your
activity. Similarly, other users will be able to view descriptions of Your activity,
communicate with You and view Your profile.

• With Your consent: We may disclose Your Personal Data for any other purpose with
Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the
purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the
extent necessary to comply with our legal obligations (for example, if We are required to
retain Your data to comply with applicable laws), resolve disputes, and enforce our legal
agreements and policies.
Where possible, We apply shorter retention periods and/or reduce identifiability by
deleting, aggregating, or anonymizing data. Unless otherwise stated, the retention periods
below are maximum periods (“up to”) and We may delete or anonymize data sooner when
it is no longer needed for the relevant purpose. We apply different retention periods to
different categories of Personal Data based on the purpose of processing and legal
obligations:

Account Information

• User Accounts: retained for the duration of your account relationship plus up to 24
months after account closure to handle any post-termination issues or resolve
disputes.

Customer Support Data

• Support tickets and correspondence: up to 24 months from the date of ticket closure
to resolve follow-up inquiries, track service quality, and defend against potential
legal claims

• Chat transcripts: up to 24 months for quality assurance and staff training purposes.

Usage Data

Website analytics data (cookies, IP addresses, device identifiers): up to 24 months
from the date of collection, which allows us to analyze trends while respecting
privacy principles.
Server logs (IP addresses, access times): up to 24 months for security monitoring
and troubleshooting purposes.

Marketing Data

Email Marketing: retained until you unsubscribe or up to 24 months from your last
engagement (last email opened or clicked), whichever comes first.
Advertising identifiers and profiles: up to 24 months from last interaction or until
you opt-out, whichever comes first.
Usage Data is retained in accordance with the retention periods described above, and may
be retained longer only where necessary for security, fraud prevention, or legal compliance.
We may retain Personal Data beyond the periods stated above for different reasons:

• Legal obligation: We are required by law to retain specific data (e.g., financial records
for tax authorities).

• Legal claims: Data is necessary to establish, exercise, or defend legal claims.
• Your explicit request: You ask Us to retain specific information.
• Technical limitations: Data exists in backup systems that are scheduled for routine
deletion.
You may request information about how long We will retain Your Personal Data by
contacting Us.
When retention periods expire, We securely delete or anonymize Personal Data according
to the following procedures:

• Deletion: Personal Data is removed from Our systems and no longer actively processed.
• Backup retention: Residual copies may remain in encrypted backups for a limited
period consistent with our backup retention schedule and are not restored except
where necessary for security, disaster recovery, or legal compliance.

• Anonymization: In some cases, We convert Personal Data into anonymous statistical
data that cannot be linked back to You. This anonymized data may be retained
indefinitely for research and analytics.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices
and in any other places where the parties involved in the processing are located. It means
that this information may be transferred to — and maintained on — computers located
outside of Your state, province, country or other governmental jurisdiction where the data
protection laws may differ from those from Your jurisdiction.
Where required by applicable law, We will ensure that international transfers of Your
Personal Data are subject to appropriate safeguards and supplementary measures where
appropriate. The Company will take all steps reasonably necessary to ensure that Your data
is treated securely and in accordance with this Privacy Policy and no transfer of Your
Personal Data will take place to an organization or a country unless there are adequate
controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We
have collected about You.
Our Service may give You the ability to delete certain information about You from within
the Service.
You may update, amend, or delete Your information at any time by signing in to Your
Account, if you have one, and visiting the account settings section that allows you to manage
Your personal information. You may also contact Us to request access to, correct, or delete
any Personal Data that You have provided to Us.
Please note, however, that We may need to retain certain information when we have a legal
obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be
transferred. We will provide notice before Your Personal Data is transferred and becomes
subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data
if required to do so by law or in response to valid requests by public authorities (e.g. a court
or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is
necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of
transmission over the Internet, or method of electronic storage is 100% secure. While We
strive to use commercially reasonable means to protect Your Personal Data, We cannot
guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party
vendors collect, store, use, process and transfer information about Your activity on Our
Service in accordance with their Privacy Policies.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports
website traffic. Google uses the data collected to track and monitor the use of our
Service. This data is shared with other Google services. Google may use the collected
data to contextualize and personalize the ads of its own advertising network.
You can opt-out of having made your activity on the Service available to Google
Analytics by installing the Google Analytics opt-out browser add-on. The add-on
prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing
information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google
Privacy & Terms web page: https://policies.google.com/privacy

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional
materials and other information that may be of interest to You. You may opt-out of receiving
any, or all, of these communications from Us by following the unsubscribe link or
instructions provided in any email We send or by contacting Us.
We may use Email Marketing Service Providers to manage and send emails to You.

Pipedrive

Their Privacy Policy can be viewed at https://www.pipedrive.com/en/privacy

Behavioral Remarketing

The Company uses remarketing services to advertise to You after You accessed or visited
our Service. We and Our third-party vendors use cookies and non-cookie technologies to
help Us recognize Your Device and understand how You use our Service so that We can
improve our Service to reflect Your interests and serve You advertisements that are likely to
be of more interest to You.
These third-party vendors collect, store, use, process and transfer information about Your
activity on Our Service in accordance with their Privacy Policies and to enable Us to:

• Measure and analyze traffic and browsing activity on Our Service
• Show advertisements for our products and/or services to You on third-party websites
or apps

• Measure and analyze the performance of Our advertising campaigns
Some of these third-party vendors may use non-cookie technologies that may not be
impacted by browser settings that block cookies. Your browser may not permit You to block
such technologies. You can use the following third-party tools to decline the collection and
use of information for the purpose of serving You interest-based advertising:

• The NAI’s opt-out platform: https://www.networkadvertising.org/choices/
• The EDAA’s opt-out platform https://www.youronlinechoices.com/
• The DAA’s opt-out platform: https://optout.aboutads.info/?c=2&lang=EN
You may opt-out of all personalized advertising by enabling privacy features on Your mobile
device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See
Your mobile device Help system for more information.
We may share information, such as hashed email addresses (if available) or other online
identifiers collected on Our Service with these third-party vendors. This allows Our third-
party vendors to recognize and deliver You ads across devices and browsers. To read more
about the technologies used by these third-party vendors and their cross-device capabilities
please refer to the Privacy Policy of each vendor listed below.
The third-party vendors We use are:

Google Ads (AdWords)

Google Ads (AdWords) remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customize the
Google Display Network ads by visiting the Google Ads Settings page:
https://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on –
https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics
Opt-out Browser Add-on provides visitors with the ability to prevent their data from
being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google
Privacy & Terms web page: https://policies.google.com/privacy

Facebook

Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this
page: https://www.facebook.com/help/516147308587266
To opt-out from Facebook’s interest-based ads, follow these instructions from
Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioural
Advertising established by the Digital Advertising Alliance. You can also opt-out
from Facebook and other participating companies through the Digital Advertising
Alliance in the USA https://www.aboutads.info/choices/, the Digital Advertising
Alliance of Canada in Canada https://youradchoices.ca/ or the European Interactive
Digital Advertising Alliance in Europe https://www.youronlinechoices.eu/, or opt-
out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook’s
Data Policy: https://www.facebook.com/privacy/explanation

CCPA/CPRA Privacy Notice (California Privacy Rights)

This privacy notice section for California residents supplements the information contained
in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the
State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being
associated with, or could reasonably be linked, directly or indirectly, with a particular
Consumer or Device. The following is a list of categories of personal information which We
may collect or may have been collected from California residents within the last twelve (12)
months.
Please note that the categories and examples provided in the list below are those defined in
the CCPA/CPRA. This does not mean that all examples of that category of personal
information were in fact collected by Us, but reflects our good faith belief to the best of Our
knowledge that some of that information from the applicable category may be and may
have been collected. For example, certain categories of Personal Information would only be
collected if You provided such personal information directly to Us.
Category A: Identifiers.
Examples: A real name, alias, postal address, unique personal identifier, online
identifier, Internet Protocol address, email address, account name, driver’s license
number, passport number, or other similar identifiers.
Collected: Yes.
Category B: Personal information categories listed in the California Customer
Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: A name, signature, physical characteristics or description, address,
telephone number, passport number, driver’s license or state identification card
number, insurance policy number, education, employment, employment history,
bank account number, credit card number, debit card number, or any other financial
information, medical information, or health insurance information.
Some personal information included in this category may overlap with other
categories.
Collected: Yes.
Category C: Protected classification characteristics under California or federal
law.
Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship,
religion or creed, marital status, medical condition, physical or mental disability, sex
(including gender, gender identity, gender expression, pregnancy or childbirth and
related medical conditions), sexual orientation, veteran or military status, genetic
information (including familial genetic information).
Collected: No.
Category D: Commercial information.
Examples: Records of personal property, products or services purchased, obtained,
or considered, or other purchasing or consuming histories or tendencies.
Collected: No.
Category E: Biometric information.
Examples: Genetic, physiological, behavioral, and biological characteristics, or
activity patterns used to extract a template or other identifier or identifying
information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans,
keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Collected: No.
Category F: Internet or other similar network activity.
Examples: Browsing history, search history, information on a consumer’s
interaction with a website, application, or advertisement.
Collected: Yes.
Category G: Geolocation data.
Examples: Approximate physical location, physical location or movements.
Collected: No.
Category H: Sensory data.
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Collected: No.
Category I: Professional or employment-related information.
Examples: Current or past job history or performance evaluations.
Collected: No.
Category J: Non-public education information (per the Family Educational
Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Examples: education records directly related to a student maintained by an
educational institution or party acting on its behalf, such as grades, transcripts, class
lists, student schedules, student identification codes, student financial information,
or student disciplinary records.
Collected: No.
Category K: Inferences drawn from other personal information.
Examples: Profile reflecting a person’s preferences, characteristics, psychological
trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected: No.
Category L: Sensitive personal information.
Examples: Government-issued identifying numbers, financial account details,
genetic data, precise geolocation, race or ethnicity, religious or philosophical beliefs,
union membership, mail, email, text messages, biometric data, health data, and
sexual orientation or sex life.
Collected: No.
Under CCPA/CPRA, Personal Information does not include:

• Publicly available information from government records
• Deidentified or aggregated consumer information
• Information excluded from the CCPA/CPRA’s scope, such as:
• Health or medical information covered by the Health Insurance Portability and
Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical
Information Act (CMIA) or clinical trial data

• Personal Information covered by certain sector-specific privacy laws, including the
Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California
Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of
1994

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories
of sources:

• Directly from You. For example, from the forms You complete on our Service,
preferences You express or provide through our Service.

• Indirectly from You. For example, from observing Your activity on our Service.
• Automatically from You. For example, through cookies We or our Service Providers
set on Your Device as You navigate through our Service.

• From Service Providers. For example, third-party vendors to monitor and analyze the
use of our Service, third-party vendors to deliver targeted advertising to You, or other
third-party vendors that We use to provide the Service to You.

Use of Personal Information

We may use or disclose personal information We collect for “business purposes” or
“commercial purposes” (as defined under the CCPA/CPRA), which may include the
following examples:

• To operate our Service and provide You with Our Service.
• To provide You with support and to respond to Your inquiries, including to investigate
and address Your concerns and monitor and improve our Service.

• To fulfill or meet the reason You provided the information. For example, if You share
Your contact information to ask a question about our Service, We will use that personal
information to respond to Your inquiry.

• To respond to law enforcement requests and as required by applicable law, court order,
or governmental regulations.

• As described to You when collecting Your personal information or as otherwise set forth
in the CCPA/CPRA.

• For internal administrative and auditing purposes.
• To detect security incidents and protect against malicious, deceptive, fraudulent or
illegal activity, including, when necessary, to prosecute those responsible for such
activities.

• Other purposes consistent with the context in which the information was collected, or
as otherwise disclosed to You at the time of collection.
Please note that the examples provided above are illustrative and not intended to be
exhaustive. For more details on how we use this information, please refer to the “Use of
Your Personal Information” section.
If We decide to collect additional categories of personal information or use the personal
information We collected for materially different, unrelated, or incompatible purposes, We
will update this Privacy Policy.

Disclosure of Personal Information

We may use or disclose and may have used or disclosed in the last twelve (12) months the
following categories of personal information for business or commercial purposes:
Category A: Identifiers
Category B: Personal information categories listed in the California Customer
Records statute (Cal. Civ. Code § 1798.80(e))
Category F: Internet or other similar network activity
Please note that the categories listed above are those defined in the CCPA/CPRA. This does
not mean that all examples of that category of personal information were in fact disclosed,
but reflects our good faith belief to the best of our knowledge that some of that information
from the applicable category may be and may have been disclosed.
When We disclose Personal Information for a business purpose or a commercial purpose,
We enter a contract that describes the purpose and requires the recipient to both keep that
personal information confidential and not use it for any purpose except performing the
contract.

Sharing of Personal Information

We may share, and have shared in the last twelve (12) months, Your personal information
identified in the above categories with the following categories of third parties:
Service Providers
Our affiliates
Our business partners
Third-party vendors to whom You or Your agents authorize Us to disclose Your
personal information in connection with products or services We provide to You

Sale of Personal Information

As defined in the CCPA/CPRA, “sell” and “sale” mean selling, renting, releasing, disclosing,
disseminating, making available, transferring, or otherwise communicating orally, in
writing, or by electronic or other means, a Consumer’s personal information by the
Business to a third party for valuable consideration. This means that We may have received
some kind of benefit in return for sharing personal information, but not necessarily a
monetary benefit.
We do not “sell” or “share” information as most people would commonly understand these
terms – meaning We do not, and will not, disclose Your Personal Information in direct
exchange for money or some other form of payment.
We allow Our Service Providers to use Your personal information for the business purposes
described in Our Privacy Policy, for activities such as advertising, marketing, and analytics,
and these may be deemed a “sale” under CCPA/CPRA. For example, when We promote Our
Service, We use Service Providers that market Our Service online, measure the marketing
efforts, identify users that are interested in Our Service, etc. This is done by placing tracking
technologies on our website such as cookies, tags, pixels, or similar, and by placing these
technologies, online identifiers and online behavior information is shared with such
vendors, including for “cross-context behavioral advertising”. Under the CCPA, these
practices are defined as “sharing” or “selling” Personal Information.
We may disclose or may have disclosed in the last twelve (12) months the following
categories in a manner that may be considered a “sale” or “sharing” as defined in
CCPA/CPRA:
Category A: Identifiers
Category B: Personal information categories listed in the California Customer
Records statute (Cal. Civ. Code § 1798.80(e))
Category F: Internet or other similar network activity
Please note that the categories listed above are those defined in the CCPA/CPRA. This does
not mean that all examples of that category of personal information were in fact sold, but
reflects our good faith belief to the best of Our knowledge that some of that information
from the applicable category may be and may have been shared for value in return.

Retention of Personal Information

We retain California residents’ Personal Information for as long as reasonably necessary to
achieve the purposes described in this Privacy Policy (including the purposes disclosed in
this CCPA/CPRA notice), taking into account: (i) how long we need the information to
provide and maintain the Service and Your Account; (ii) whether You have requested
deletion (subject to applicable exceptions); (iii) Our legal, tax, accounting, and regulatory
obligations; (iv) security, fraud prevention, and abuse monitoring needs; and (v) the time
periods needed to resolve disputes and enforce Our agreements.
Specific retention periods for major data categories are described in the “Retention of Your
Personal Information” section of Our Privacy Policy, and We may retain certain information
longer where required or permitted by law (for example, to comply with recordkeeping
obligations or to establish, exercise, or defend legal claims).

Sale of Personal Information of Minors Under 16 Years of Age

We do not knowingly collect personal information from minors under the age of 16 through
our Service, although certain third party websites that we link to may do so. These third-
party websites have their own terms of use and privacy policies and We encourage parents
and legal guardians to monitor their children’s Internet usage and instruct their children to
never provide information on other websites without their permission.
We do not sell the Personal Information of Consumers We actually know are less than 16
years of age, unless We receive affirmative authorization (the “right to opt-in”) from the
parent or guardian of a Consumer less than 16 years of age. Consumers who opt-in to the
sale of personal information may opt-out of future sales at any time. To exercise the right to
opt-out, You (or Your authorized representative) may submit a request to Us by contacting
Us.
If You have reason to believe that a child under the age of 16 has provided Us with personal
information, please contact Us with sufficient detail to enable Us to delete that information.

Your Rights under the CCPA/CPRA

The CCPA/CPRA provides California residents with specific rights regarding their personal
information. If You are a resident of California, You have the following rights:

• The right to notice. You have the right to be notified which categories of Personal
Information are being collected and the purposes for which the Personal Information is
being used.

• The right to know/access. Under CCPA/CPRA, You have the right to request that We
disclose information to You about Our collection, use, sale, disclosure for business
purposes and share of personal information. Once We receive and confirm Your request,
We will disclose to You:

• The categories of personal information We collected about You
• The categories of sources for the personal information We collected about You
• Our business or commercial purposes for collecting or selling that personal
information

• The categories of third parties with whom We share that personal information
• The specific pieces of personal information We collected about You
• If we sold Your personal information or disclosed Your personal information for a
business purpose, We will disclose to You:

• The categories of personal information categories sold
• The categories of personal information categories disclosed
• The right to say no to the sale or sharing of Personal Information (opt-out). You
have the right to direct Us to not sell Your personal information. To submit an opt-out
request, please see the “Do Not Sell or Share My Personal Information” section or
contact Us.

• The right to correct Personal Information. You have the right to correct or rectify any
inaccurate personal information about You that We collected. Once We receive and
confirm Your request, We will use commercially reasonable efforts to correct (and
direct our Service Providers to correct) Your personal information, unless an exception
applies.

• The right to limit use and disclosure of sensitive Personal Information. You have
the right to request to limit the use or disclosure of certain sensitive personal
information We collected about You, unless an exception applies. To submit, please see
the “Limit the Use or Disclosure of My Sensitive Personal Information” section or
contact Us.

• The right to delete Personal Information. You have the right to request the deletion
of Your Personal Information under certain circumstances, subject to certain
exceptions. Once We receive and confirm Your request, We will delete (and direct Our
Service Providers to delete) Your personal information from our records, unless an
exception applies. We may deny Your deletion request if retaining the information is
necessary for Us or Our Service Providers to:

• Complete the transaction for which We collected the personal information, provide
a good or service that You requested, take actions reasonably anticipated within the
context of our ongoing business relationship with You, or otherwise perform our
contract with You.

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal
activity, or prosecute those responsible for such activities.

• Debug products to identify and repair errors that impair existing intended
functionality.

• Exercise free speech, ensure the right of another consumer to exercise their free
speech rights, or exercise another right provided for by law.

• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code
§ 1546 et. seq.).

• Engage in public or peer-reviewed scientific, historical, or statistical research in the
public interest that adheres to all other applicable ethics and privacy laws, when the
information’s deletion may likely render impossible or seriously impair the
research’s achievement, if You previously provided informed consent.

• Enable solely internal uses that are reasonably aligned with consumer expectations
based on Your relationship with Us.

• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the
context in which You provided it.

• The right not to be discriminated against. You have the right not to be discriminated
against for exercising any of Your consumer’s rights, including by:

• Denying goods or services to You
• Charging different prices or rates for goods or services, including the use of
discounts or other benefits or imposing penalties

• Providing a different level or quality of goods or services to You
• Suggesting that You will receive a different price or rate for goods or services or a
different level or quality of goods or services

Exercising Your CCPA/CPRA Data Protection Rights

Please see the “Do Not Sell or Share My Personal Information” section and “Limit the Use or
Disclosure of My Sensitive Personal Information” section for more information on how to
opt out and limit the use of sensitive information collected.
Additionally, in order to exercise any of Your rights under the CCPA/CPRA, and if You are a
California resident, You can contact Us:

• By email: in**@**********es.com
Only You, or a person registered with the California Secretary of State that You authorize to
act on Your behalf, may make a verifiable request related to Your personal information.
Your request to Us must:

• Provide sufficient information that allows Us to reasonably verify You are the person
about whom We collected Personal Information or an authorized representative

• Describe Your request with sufficient detail that allows Us to properly understand,
evaluate, and respond to it
We cannot respond to Your request or provide You with the required information if We
cannot:

• Verify Your identity or authority to make the request
• And confirm that the personal information relates to You
We will disclose and deliver the required information free of charge within 45 days of
receiving Your verifiable request. The time period to provide the required information may
be extended once by an additional 45 days when reasonably necessary and with prior
notice.
Any disclosures We provide will only cover the 12-month period preceding the verifiable
request’s receipt.
For data portability requests, We will select a format to provide Your personal information
that is readily usable and should allow You to transmit the information from one entity to
another entity without hindrance.

Do Not Sell or Share My Personal Information

Website

If applicable, click “Privacy Preferences”, “Update Privacy Preferences” or “Do Not Sell or
Share My Personal Information” buttons listed on the Service to review Your privacy
preferences and opt out of cookies and other technologies that We may use. Please note that
You will need to opt out from each browser that You use to access the Service.
Additionally, You can opt out of receiving ads that are personalized as served by our Service
Providers by following our instructions presented on the Service:

• The NAI’s opt-out platform: https://www.networkadvertising.org/choices/
• The EDAA’s opt-out platform https://www.youronlinechoices.com/
• The DAA’s opt-out platform: https://optout.aboutads.info/?c=2&lang=EN
The opt-out will place a cookie on Your computer that is unique to the browser You use to
opt out. If you change browsers or delete the cookies saved by Your browser, You will need
to opt out again.

Mobile Devices

Your mobile device may give You the ability to opt out of the use of information about the
apps You use in order to serve You ads that are targeted to Your interests:

• “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
• “Limit Ad Tracking” on iOS devices
You can also stop the collection of location information from Your mobile device by
changing the preferences on Your mobile device.

Limit the Use or Disclosure of My Sensitive Personal Information

If You are a California resident, You have the right to limit the use and disclosure of Your
sensitive personal information to that use which is necessary to perform the services or
provide the goods reasonably expected by an average consumer who requests such services
or goods.
We collect, use and disclose sensitive personal information in ways that are necessary to
provide the Service. For more information on how We use Your personal information,
please see the “Use of Your Personal Information” section or contact us.
To submit a request to limit the use or disclosure of sensitive personal information, please
contact Us using the methods listed in the “Contact Us” section of Our Privacy Policy.
“Do Not Track” Policy as Required by California Online Privacy Protection Act
(CalOPPA)
Our Service does not respond to Do Not Track signals.
However, some third-party websites do keep track of Your browsing activities. If You are
visiting such websites, You can set Your preferences in Your web browser to inform
websites that You do not want to be tracked. You can enable or disable DNT by visiting the
preferences or settings page of Your web browser.

Your California Privacy Rights (California’s Shine the Light law)

Under California Civil Code Section 1798 (California’s Shine the Light law), California
residents with an established business relationship with Us can request information once a
year about sharing their Personal Data with third parties for the third parties’ direct
marketing purposes.
If you’d like to request more information under the California Shine the Light law, and if You
are a California resident, You can contact Us using the contact information provided below.
California Privacy Rights for Minor Users (California Business and Professions
Code Section 22581)
California Business and Professions Code Section 22581 allows California residents under
the age of 18 who are registered users of online sites, services or applications to request
and obtain removal of content or information they have publicly posted.
To request removal of such data, and if You are a California resident, You can contact Us
using the contact information provided below, and include the email address associated
with Your Account.
Be aware that Your request does not guarantee complete or comprehensive removal of
content or information posted online and that the law may not permit or require removal in
certain circumstances.

Children’s Privacy

Our Service does not address anyone under the age of 16. We do not knowingly collect
personally identifiable information from anyone under the age of 16. If You are a parent or
guardian and You are aware that Your child has provided Us with Personal Data, please
contact Us. If We become aware that We have collected Personal Data from anyone under
the age of 16 without verification of parental consent, We take steps to remove that
information from Our servers.
If We need to rely on consent as a legal basis for processing Your information and Your
country requires consent from a parent, We may require Your parent’s consent before We
collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a
third party link, You will be directed to that third party’s site. We strongly advise You to
review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or
practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by
posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our Service, prior to the
change becoming effective and update the “Last updated” date at the top of this Privacy
Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this
Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

• By email: in**@**********es.com